Subj: |
Urgent to meet you RE: CCNPP safety concerns |
Date: |
7/24/2003 12:19:33 PM Central Daylight Time |
From: |
|
To: |
Dear Mr. Wallace:
I urgently request to meet with you to discuss the following two items at your
earliest convenience:
1. My Safety Concerns at CCNPP.
2. CCNPP's blackballing me for employment due to knowledge of my prior protective
activity.
1. I raised some concerns during your Calvert Cliffs Nuclear Power Plant (CCNPP)
Unit 2 Steam Generator Replacement (SGR) Project regarding the inappropriate
design control processes for Systems, Structures, and Components (SSCs). I had
questioned the inappropriate resolutions of the following items for design and
operability concerns:
A.) Concrete Repair of the Pressurizer Wall (dog house) and
B.) Out of plumpness of the supporting structures/variable spring hanger deficiencies
and dispositions discovered during the non-defueled mode (mode 4) subjected
to HELB and seismic loading.
I believe that my concerns had not been adequately addressed in the design
and operability evaluation for CCNPP despite the fact that I had fully elaborated
my concerns to your engineers and managers. I also had documented my reasons
on the daily activity log. These logs were read by other cognizant engineers
who supported my issues.
For example, the actual purred concrete samples testing by the concrete testing
manufacturer revealed that the repaired concrete shear capacity was within 2000
pounds per square inches and not the required 4000 minimum requirements for
the plant's design and operation for mode 4 where the concrete bursting had
occurred and still required to meet the High Energy Line Break (HELB) and seismic
loading. I had appropriately brought these issues to the attention of your staff
and the designated technical specialist who signed the closure of the issue
when I refused to sign and accept the final resolution even on my last day (April
18, 2003). I was designated as your structural engineer during the split shift
coverage of SGR Unit 2 from Jan. 06 till April 18, 2003.
I provided some brief discussion of this issue the week after my last day of
April 18, 2003 when I provided my complimentary training to your management,
procurement, and engineering staff. I did not inform your management in a form
of an allegation, but rather as the information awareness (actually reflected
as one of my design examples in my handout of 119 pages).
Your QA Procurement staff became concerned when I described the mode 4 and defueld
requirements and its impact on the plants' operations for the concerned items.
After the training, some of your Procurement QA Staff told me that this was
not included in their scope of activities, because CCNPP management had instructed
its internal QA that the SGT Company would cover the oversight function of SGR
Project and not CCNPP internal QA. This seamed very strange, because CCNPP still
needs to audit SGT to ensure full compliance with the applicable codes of federal
regulations per 10CFR50 Appendix B, Criteria VII, XVI, and XVIII for adequate
implementation of Criterion III (Design Control) processes.
Regulation: Criterion VII of 10CFR50 Appendix B requires the control
of items, components, and services. The licensee (CCNPP) is ultimately responsible
for the adequate implementation of its vendor's QA Program. SGT's QA Program
in this regard did not meet the code requirements for commercial grade dedication
(safety related activity per EPRI 5652, NCIG-07) and the sample testing of concrete
strength requirements (design control deficiencies) for the above issues and
the Licensee is ultimately responsible for its nuclear safety. The SGT’s root
cause evaluation report was not correct, because the maximum calculated stress
in the concrete was determined to be 3600 pounds and less than 4800 pound allowable
shear stress. 3600 is less that 4800 and if the calculation was correct, then
the concrete would have not burst. This is the indicative that the existing
concrete may not have been meeting its original design intent. Once I raised
this issue, SGT management decided to rescind its root cause evaluation report
and calculation and declared that SGT QA Program does not require any root cause
evaluation. I explained that if SGT QA Program does not require the root cause
evaluation, then it would not meet the intent of 10CFR50 Appendix B requirements.
In addition, CCNPP was supposed to hire two concrete experts from ACI Committee
to investigate the concrete crack issue and satisfy all the concerns raised
for concrete crack, but this never occurred. I urged CCNPP management to send
some samples of the fixed concrete prior to returning the CCNPP Unit 2 into
operational mode of 4, 5, and fully operational. The test results confirmed
that my concerns were accurate and the concrete shear capacity was around 2000
psi and much less than 4000 psi required strength. I was told that Bill Holston,
as the Engineering Manager of CCNPP had indicated that he was the committee
member of ASME Section XI and could justify that the root cause evaluation for
concrete and for the spring hanger support that was found out of plump is not
necessary and the concrete does not need to have enough shear strength to withstand
the mode 4 and operational requirements. If Mr. Hostrom had made this statement,
then he is not correct.
2. Your staff at CCNPP became fully aware of my protected activity (whistle
blowing) case against Exelon. I had discussed my issues in full depth with one
of your mechanical engineers who was my mechanical engineer partner in the same
shift. I introduced him to you on January 2003 at the gatehouse. I have another
witness within your staff that tried to find me a job at your CCNPP. He approached
one of your Reactor Head Project Managers, Mr. Bill Tench to highlight my qualification
and expertise in the Codes for an employment opportunity. Mr. Tench told him:
"Make sure that the person whom you are talking about and is giving us the training
of ASME Tutorial Course today gives me his Resume ASAP before he leaves the
site". My witness paged me immediately when I was leaving CCNPP. I sent him
my electronic Resume. My witness went to see Mr. Tench the next day. My witness
told me that Mr. Tench had already printed my Resume and had it in front on
his desk. My witness asked Mr. Tench: "what do you think about his credentials
as shown in his Resume?" Mr. Tench replied to my witness: "this is the
person that I really need to help me with this project due to his knowledge
and code expertise showing on his Resume, but do you know really who he is?
I knew him from ComEd, Oscar had brought many issues against Exelon and he is
PAIN IN THE ASS, but technically very good. I would love to hire him, but my
boss who also came from ComEd would not want to hire Oscar, but I need him and
if it was up to me, I would not hesitate".
From April 2003 up to now I have not been contacted for this position at all
despite my frequent contacts with reactor head managers whom I knew during my
service at CCNPP. My witness has reminded Mr. Tench a couple of times, but heard
nothing and advised me to contact you since I knew you from ComEd. I also need
to protect the identity of my witness not to be the subject of any retaliation
for revealing this news to me. The above statements from your manager, Mr. Tench
show clearly that he was aware of my protective activity at Exelon and refused
to hire me. If it were my Resume with no name, I would have been working for
you since April 2003 or I might have not left your site. This is unlawful.
Note: In another incident, I also had sent you my Resume and one of your staff,
Mr. Ken. Boone had sent a request to your HR in early June 2003 to send me some
questionnaire electronically and I replied to the subject request. This opportunity
was not specific to any task and assignments. I have called many times to your
HR designated individual to find out the status of my application, but I have
not heard any reply to my repeated messages. The subject e-mail would be provided
upon your request.
The reason that I want to discuss the details of the above two items with you
is because I trust in you and know that you would not tolerate any quality compromises
at your CCNPP. I knew you from the ComEd time frame of 1990-1997 and I highly
trust your integrity and ethics. The management who replaced you destroyed all
the ComEd's integrity by increasing the power uprate at any cost and that is
why they selling more electricity than when you were there. There have been
three incidences of Exelon's nuclear plants forced shutdown at Dresden, Quad
Cities, and Byron due to Power Uprate as quoted by August 2002 INPO documents.
At ComEd, I had met with you and received highest achievement awards from your
designated engineering VPs and managers for the standards and codes that I developed
and incidences that I defended ComEd engineering positions with NRC/NRR. I wrote
codes to defend the operability of our nuclear plants. I knew you as a man who
would not jeopardize the integrity of its plants and staff at the price of the
production and the influence of other partners who have no ethics and are known
as the killers of safety advocates. You promoted me three times within 5 years
and I like to thank you, because you realized my contribution to ComEd nuclear
plants. When I contributed to the success of ComEd/Exelon I was not recognized
by Kingsley and when I found issues that I could not hide in order to protect
my job and the company’s position with the regulators, then I was kicked out.
I strongly believe that when you left ComEd, the management intimidation and
fear at Exelon started and destroyed any freedom to bring safety issues to the
management attention. When I was at engineering and produced standards and codes
to defend our plants I was rewarded by your staff, but the whole picture changed
when you left. Production took the front seat and quality was thrown to garbage
as well as safety issues. Please refer to NRC's citation on October 4, 2002
against Exelon who willfully discriminated against a Byron Employee Concerns
Program's (ECP) Supervisor who said: "There is a Chilled Atmosphere at Exelon
and employees are afraid of their jobs to bring safety concerns to the ECP staff".
I had met with you on a couple of occasions and you showed care and attention
to the personal issues as well as nuclear safety issues. I know that you would
not tolerate any of your management’s actions to blackball me for employment
at your company. I would be part of the solution and not problems at your company.
In fact, I want to ensure that your reactor head project would implement quality
into design and fabrication at the beginning to fully meet the codes and standards.
I will give you my full commitment to ensure code compliance.
I never had intended to be a whistle blower or be destructive to the nuclear
power industry that I proudly served for 21 years, but could not walk on my
ethics and integrity to protect myself and Exelon for criminal wrong doings.
I did not want to be a subject of criminal prosecution per 10CFR50.110 to wrongfully
protect my job and hide the Exelon's falsification of records as displayed in
my DOL hearing, which is in appeal process. Unfortunately these DOL hearing
lasts for many years of frustration, but I need to feed my family and serve
the nuclear industry that I proudly served.
Background Information:
I had raised 9 significant allegations against Exelon and specifically Messrs.:
Oliver Kingsley and David Helwig due to my Stop Work Order against GE, Holtec,
US Tool & Die, and Exelon and their retaliation against me when I told NRC.
I had exhausted all my avenues internally at Exelon and escalated the issues
to management, but when I was ignored, insulted, removed by conspiracy from
Exelon, then I had no choice to tell NRC. Later I found that Exelon falsified
records to lie to NRC and NRC did not catch them. That is why I was at OIG in
July 21 and 22, 2003 to let them know about the shortcomings and incompetence
of NRC as the guardians of public health and nuclear safety.
As you may be aware by numerous media coverage (i.e. Associated Press, Salt
Lake Tribune, Las Vegas Sun, Las Vegas Review Journal, San Francisco Bay AlterNet,
etc.) that one of my 9 allegations against Exelon/Holtec spent nuclear fuel
dry cask storage. All the media coverage started in June and July 2003 which
my issues were escalated by the Senator Reid's staff to the national attention
and NRC/OIG. These media stories for public health and nuclear safety have unintentionally
further blackballed me from the employment and I don't regret it at all, because
the price of integrity and ethics is very high.
I have been unemployed from October 2001 till now except the three months that
I was at your CCNPP (thanks). I have witnesses that even NUPIC Utilities knew
about my issues with Exelon from the first day that Exelon terminated me in
October 2001. Russell A. Bastyr, my last boss in Exelon Nuclear is the Secretary
of NUPIC. Demark Owner, Mr. Mark Inserra tried to find me a job at the First
Energy's Beaver Valley NPP and everything was all set for me to start on June
30, 2003, but First Energy VP has stopped the offer when they found out that
this new person coming to their site is Oscar Shirani (of Course, this is not
admitted by Demark). Mark Inserra who has incentive to employ me for a mutual
interest is not even responding to my repeated phone calls from June 30, 2003
up to now. I had left him several messages that I am a grown person and could
digest the bad news and please tell me why?, but he refuses to call me back
to admit to any inside information that he might know.
NRC staff failed to identify the issues that I raised at GE, Holtec, US Tool
& Die and other suppliers that they inspected prior to my design assessments.
Exelon's history is full of willful violations. You may read about my issues
on the Internet by searching "Oscar Shirani" and all the media coverage of one
of my 9 allegations against Exelon is displayed.
Please make an arrangement to meet with me at your earliest convenience.
Best regards!
Oscar Shirani
Tel: 630-790-9650
Cell: 630-745-0381
This document was posted online December, 2003 by Russell D. Hoffman. For a complete guide to Oscar Shirani's allegations please visit:
http://www.animatedsoftware.com/environment/whistleblowers/OShirani/Oscar_Shirani.cfm